Carrillo v. Commissioner of Social Security

Filing 19

ORDER signed by Magistrate Judge Kendall J. Newman on 8/12/2014 APPROVING the stipulation between the parties extending time from 8/11/14 to 9/2/2014 for defendant to file an opposition to plaintiff's opening brief or otherwise respond to plaintiff's motion for summary judgment. The court is disinclined to grant any further extensions absent extraordinary circumstances. (Yin, K)

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BENJAMIN WAGNER CSBN 163581
United States Attorney
DONNA L. CALVERT
Regional Chief Counsel, Region IX
Social Security Administration
MARLA K. LETELLIER, CSBN 234969
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant
UNITED STATES DISTRICT COURT
Attorneys for Defendant
EASTERN DISTRICT OF CALIFORNIA
Attorneys for Defendant
ODILIA CARRILLO,
Plaintiff,
vs.

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CAROLYN W. COLVIN,
Acting Commissioner of
Social Security,

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Defendant.

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CIVIL NO. 2:13-cv-02401-KJN
ORDER APPROVING STIPULATION
FOR EXTENSION OF TIME FOR
DEFENDANT TO RESPOND TO
PLAINTIFF’S MOTION FOR
SUMMARY JUDGMENT
(SECOND REQUEST)

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IT IS HEREBY STIPULATED, by and between the undersigned attorneys, subject to the

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approval of the Court, that Defendant shall have a twenty-one day extension, from August 11, 2014 to

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September 2, 2014, in which to file her Opposition to Plaintiff’s Opening Brief or otherwise respond to

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Plaintiff’s motion.

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This request is the result of a heavy workload for counsel responsible for briefing this case. For

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example, in the next three weeks counsel is responsible for briefing dispositive motions in five matters,

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as well as significant other agency matters such as multiple civil rights complaints and agency legal

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opinions. Additionally, this extension is needed because counsel for Defendant will be out of the office

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from August 15, 2014 until August 25, 2014.

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Stip for EOT, 2:13-cv-02401-KJN

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This request is not meant to cause intentional delay.

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Respectfully submitted,

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BENJAMIN WAGNER
United States Attorney

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Dated: August 11, 2014

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By: /s/ Marla K. Letellier
MARLA K. LETELLIER
Special Assistant United States Attorney
Attorneys for Defendant

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CERNEY KREUZE & LOTT, LLP

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Dated: August 11, 2014

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By: /s/ Shellie Lott
SHELLIE LOTT
Attorney for Plaintiff
(as approved by email on August 11, 2014)

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PURSUANT TO STIPULATION, IT IS SO ORDERED. However, the court notes that

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defendant has previously received a 45-day extension and now a 21-day extension. Although the court

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is sympathetic to counsel’s workload, the court is disinclined to grant any further extensions absent

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extraordinary circumstances.
Dated: August 12, 2014

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Stip for EOT, 2:13-cv-02401-KJN

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